1

SPH

- 2134068

- 1 UASolutions Group, Inc. 2518 Auburn Drive, Cocoa FL 32926 Tel: (321) 261

- 2547

Kelly n eubecker@uasolutionsgroup.com

April 16

, 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

Re : Petition for an Exemption to Conduct Small Unmanned Aircraft Systems (s UAS ) Operations Allowed by Section 333 of the Federal Aviation Administration Modernization and Reform Act of 2012 , 49 U.S.C. § 44701(f), and 14 C.F.R. Part 11

A. Summary
On behalf of our clients, Elevated Horizons, LLC, and p ursuant to Section 333 of the
Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (“FMRA”)

, Subs ec ti on ( f

) of 49 U

. S

. C

. § 44701

, and 14 C.F.R. Part 11

, Elevated Horizons, LLC ( “ Elevated

Horizons ”)

, ( hereafter known as the “Petitioner”)

, an operator of Small Unmanned Aircraft Systems (“sUAS”) equipped to conduct aerial imaging and surveying

, seeks exemption from the following listed Code of Federal Regulations (“CFR”) to allow commercial operation of the DJI
Spreading Wings S 1000 (“S 1000 ”) within the N ational A irspace System (NAS) for controlled,

low

- risk

, precision agriculture operations for standard monitoring, yield, and production
intervals, specializing in disease detection, conducted within and under the conditions outlined

herein

, or as may be established by the F AA, as required by Section 333 requirements

. As described more fully below, the requested exemption would permit the operation of

the S1000 s UAS by Petitioner under controlled conditions in predetermined airspace that is
1) Limited in scope 2 ) Controlled as to access by mission essential personnel o nly and

3 ) Provides improved safety controls and efficiency to the agricultural industry presently using

conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the2

Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system” as
stated within Section 333(c) of the FMRA. In making this determination, the Secretary is
required to determine which types of s UAS do no t create a hazard to users of t h e NAS or the public or pose a threat to national security in light of the aircraft’s size, weight, speed and
operational capability; Operation of the s UAS in close proximity to airports and population
centers; Oper ation of a s UAS within visual line of sight of the operator.

Grant of t h e requested exemption is in the public interest based upon the concise
direction expressed within section 333 of the reform act; the added authority granted by the Act,
as amended; an equivalent level of safety regarding flight operations as expressed herein, and
significant co st savings achieved by transitioning from traditional manned aerial resources to

s UAS s. The petitioner respectfully requests that the FAA grant the requested exemption without
delay. Petitioner will operate the S1000 sUAS while keeping the documents required by the
regulations at the ground control station and immediately accessible to the P ilot i n C ommand
(PIC) and by modification of the required markings (registration n umber) of the s UAS to be
displayed on the fuselage of the unmanned aircraft.

The name and address of the Petitioner is:

Elevated Horizons, LLC

.
The primary contact for this petition, with a copy to me at the address above is :

Ty Rosier 7449 Rex Hill Trail, Orlando, FL 32818

B. Regulations

– Exemptions Requested

a. 14 C.F.R. 45.27(a), b. 14 C.F.R

. 61.113(a) and (b),

c. 14 C.F.R

. 91.7(a), d. 1 4 C.F.R

. 91.105,

e. 14 C.F.R

. 91.119 (c) f. 14 C.F.R. 91.121,
g. 14 C.F.R

. 91.151(b), h. 14 C.F.R

. 91.405(a), i. 14 C.F.R

. 9 1.407(a)(1), j. 14 C.F.R. 91.409(a)(1) and ( 2 ), and k. 14 C.F.R. 91.417(a) and (b).3

C

. Corporate Background

Elevated Horizons is an imag ing service company, with the operational infrastructure to
provide precision aerial imagery and surveying for numerous agricultural markets in different
geograph ical locations throughout the Unites States in a safe, convenient, and legal manner

. Elevated Horizons supports the University of Florida and Florida International University and is
in current negotiations with Dole Food Company for its Rio Frio Banana fa rm in Costa Rica.

Elevated Horizons ’s sUAS for the purposes of this petition is the S1000

, w eighing
approximately 4 k g ( 8.9 lbs) with a maximum takeoff weight of about 11 kg ( 24 1lbs), including
payload, and under normal conditions at a maximum speed of no more than 16 m/s (31kts).

Elevated Horizons w ill operate only within v isual line of sight (VLOS) and during daylight
hours in Visual Flight Rules (VFR) conditions. Additionally , Elevated Horizons will operate
only within the parameters define d in the blanket Certificate of Authorization (COA) issued by

the FAA under the new interim policy. In the event any Elevated Horizon operation exceeds the

200

- foot limitation imposed by the policy, a separate COA specific to the airspace required for

th at operation will be obtained prior to flight operations. Such requirements will insure that the sUAS will “not create a hazard to users of the national airspace system or the “public” as stated

in Section 333 of the FMRA.

D. Airworthiness
A critical element of consideration for grant of the petition is evidence of an equivalent
level of safety for airworthiness of the s UAS

. The FAA has been authorized to exempt aircraft
from the requirement for an actual airworthiness certificate in accordance with the statutory
criteria provided in Section 333 of PL 112

- 95 in reference to 49 USC 44704, in consideration of
the size, weight, speed, and limited operating area associated with the aircraft and its operation.
However, in accordance with FAA N 8900.291, Petitioner has an established inspection and
maintenance program for the continued airworthiness of the aircraft in accordance wit h the manufacture’s maintenance, overhaul, replacement, inspection, and life limit requirements for
the aircraft and aircraft components.
In support of these characteristics, along with the published S1000 User’s Manual, A2
Flight Control System User Man ual, and Ground Station Wireless Data

- link User manual,

Elevated Horizons submits the following additional documents and manuals as attachments to
this exemption request

, to provide the details for review by the FAA . The following are a set of4

Confidential Documents under 14 CFR 11.35(b) as each document and manual contains
proprietary information that the applicant has not and will not share with others. The documents
and manuals contain specifications, operating conditions and procedures, mai ntenance procedures and a safety management program that are not available to the public and are
protected from release under the Freedom of Information Act 5 USC 552 et.seq.

• Elevated Horizons Standard Operating Procedures Manual ( S OP )

• Elevated Horizons Maintenance Manual (MM)

E

. DJI S1000 Summary

Petitioner seeks an exemption to operate the S1000 for limited approved com mercial

pu rposes within the NAS 1

. The S1000 is a multi

- rotor sUAS aircraft built with a carbon

airframe and a transportable ground station

. Elevated Horizons will utilize the DJI PC Ground
Control Station software operating within the 900MHz

- 2.4GHz unlicensed frequency

bandwidth. The S1000 has an empty weight of approximately 4 kg ( 8.9 lb) with a maximum

t akeoff weight 11 kg ( 24 l b )

. The S1000 carr ies 6

- Cell Lithium Polymer batteries, ranging

between 10,000

- 20,000 mAh

, which facilitates up to 1 5 minutes of flight tim e

. The S1000 will

be equipped with the DJI A2 multi

- rotor autopilot which provides a maximum cruise speed of

1 6 m/s ( 31 kts). The DJI autopilots feature auto

- takeoff and landing, auto go home and
landing, GPS waypoint navigation, direction lock, and GIS mapping.

F. Regulatory Basis for Petition

Petitioner

, pursuant to 14 C.F.R. § § 11. 6 1 (b), 11.81, 2 and the FAA Modernization and

Reform Act of 2012 ( “ FMRA ” ) , Section 333, Special Rules for Certain Unmanned Aircraft
Systems ( “ Section 333 ” ) , hereby respectfully petitions the Administrator for an exemption from

the requirements of 14 C.F.R. §§ , 45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121

, 91.151 (b)

, 91.405(a), 91.407(a)(1), 91.409(a) (1) and (2), 91.417(a) and (b)

. 1. Section 333
Congress identifies Section 333 of the FMRA, as a pathway for “ expedited operational

authorization ” of certain sUAS in the NAS

. Section 33 3 (b)(1) ( “ expedited operational

1 Elevated Horizons will submit Aircraft Registration Applications as required, upon the grant of the exemptions sought by this petition.

2 14 C.F.R. § 11. 6 1 (b) (“ Using a petition for exemption, you may ask FAA to grant you relief from current regulations in 14 C.F.R.”) , 14 C.F.R. § 11.81 (“ What information must I include in my petition for an exemption ”) ?5

authorization. ” )

. 3 Under Section 333 Congress mandates that the FAA “ shall determine if certain
unmanned aircraft systems may operate safely in the national airspace system before completion

of the plan and rulemaking required by S ection 332 of this Act or the guidance required by

section 334 of this Act ” ( Section 33 3(a) ) upon consider ation of its “ size, weight, speed, operat ional
capability, proximity to airports and populated areas, and operation within visual line of sig ht

. ”

Section 333(b) (1 ). I f the FAA makes such a determination, the FAA “ shall [also] establish
requirements for the safe operation

. ” Section 33 3(c)

. T he FAA further may find that the sUAS does
not require “ airworthiness certification under section 44704 of title 49, United States Code

. ” Section
333(b) (2)

. 2. 49 U.S.C. § 44701

T he FAA is further authorized to grant exemptions from its safety regulations and

minimum standards under 49 U.S.C. § 44701 ( “ Section 44701 ” ) “ if the Administrator finds
the exemption is in the public interest. ” Section 44701(f) 4 (authorizing the grant of
exemptions from safety regulations and minimum standards under S ection 44701(a) and (b) and

S ections 44702

- 44716). 5

For the reasons addressed herein

, this Petition q ualifies for expedited approval of

Petitioner ’s request for exemption under both Section 333 of the FMRA and 49 U.S.C § 44701

.

G. S1000 Statutory Criteria for Exemption under Section 333

G iven its small size, light weight, slow speed, limited load capacity, superior
operational capabilities

, and that the operations will be conducted only during the day, under
visual meteorological conditions ( “ VMC ” ), within V LOS of the PIC, with the assistance of a visual
safety observer ( “ VO ” )

, and confined within the boundaries of a consenting landowner’s property

and not in the proximity of airports or populated areas , the S1000 is the very category of sUAS

3 See also www.faa.gov/ sUAS /legislative_programs/section_333/ (noting that Section 333 grants the FAA “the statutory flexibility to expedite requirements for the safe operation of certain aircraft systems in the NAS.”).

4 U n d er 4 9 U

. S

. C

. § 4 47 0 1( f )

, t h e “ A d m i n i s t r at o r m a y g r a n t an e x e m p ti o n f r o m a r e q u i r e m e n t

o f a r e g u lati o n pr e s c r i b ed un d er su b s ecti o n ( a ) o r ( b ) o f t h is s ecti o n o r a n y o f s ecti o n s 44702

- 447 1 6 o f [ T i t le 49 ] if t h e A d m i n i s t r at o r f i n d s t h e e x e m p ti o n is i n t h e p u b lic i n te r e s t

. ”
5 See e.g. 49 US C §44711 ( a )(1) prohibiting operations without airworthiness certificate; (2) prohibiting serving as airman without airman’s certificate; (5) prohibiting commercial operations in violation of regulations) ; 49 US C §44 7 04 (issuance of airworthiness certificate); 14 C.F.R. §91

. 203 ( a ) ( 1 ) (carry airworthiness certificate)).6

that qualifies for expedited approval under Section 333

.

1. Operational Capability

T he S1000 was specially designed for low altitude surveillance, photography, and
cinematography. S upported by electric batteries that are rechargeable

, the S1000 can fly from

15

- 18 minutes (*depending upon atmospheric conditions) and carry a variety of cameras or

sensors

. Other Operational metrics of the S1000 are as follows:

F ra m e
D i ag o na l Wh ee l ba se 1 0 4 5 m m F ra m e A r m L en g t h 3 8 6 m m
F ra m e A r m We i g h t 3 25g ( w i t h M o t o r , E S C, P r o pe ll e r )
Ce nt e r Fr a m e D i a m ete r 337 .5 mm
Ce nt e r F ra m e We i g h t ( w i t h Land i n g Gea r 1 3 3 0 g M o unt i n g Ba se , S e r v o s )
46 0 m m ( L en g t h ) × 5 1 1 m m ( W i d t h ) × 3 0 5 m m ( H e i g h t ) L a nd i n g G ea r S i z e ( Top w i d t h : 155 m m )

M o t or

S t a t or Si ze 41 × 1 4 m m

k V 4 0 0 r p m / V

M a x Pow e r 5 0 0 W

We i g h t ( w i t h C o ol i n g Fa n ) 1 5 8 g
ESC

Wor k i n g Cu rre n t 4 0 A

Wor k i n g Vol ta g e 6S L i Po

S i g na l Fr e q uen cy 3 0 H z ~ 4 5 0 H z
Dri v e PW M Fr e q uen cy 8 K Hz

We i g h t (w i t h R a d i at o r s) 3 5g
Fol dab le P r o pe ll e r (1 5 52/1 5 52 R )

M ater i a l H i g h s tren g t h per fo r m an ce en gi neere d p l a s t i cs

S i z e 1 5 × 5. 2 i n ch

We i g h t 1 3 g

Fl i g h t P a r a m e t e r s

T a keoff We i g h t 6. 0 K g ~ 1 1

. 0 K g

To ta l We i g h t 4

. 2 K g

Po we r Ba t t e r y L i Po ( 6 S

, 1 0 00 0 m A h

~ 2 0 0 00 m A h

, 1 5 C ( M i n ) )7

M a x Pow e r C o n s u m pt i on 4 00 0 W

Ho v e r i n g P o w e r C o n s u m pti on 15 0 0 W (@ 9 .5 K g Tak e o ff W e ig ht )

Ho v e r i n g T i m e 1 5m i n (@1 5 0 0 0m A h & 9 .5 K g T a keoff W e ig ht )

Wor k i n g E n v i r o n m en t T e mp e rat u r e - 10 o C

~ + 40 o C

2. Proximity to Airports/Populat ion Centers or A reas

F light o pe r a t i ons pursuant to t h i s Petition w i l l be t i g h t l y con t r o ll ed and restricted to

low risk rural areas and in accordance with the blanket 200

- foot COA requirements at an altitude
of no more than 200 feet above ground level (AGL). In the event an Elevated Horizon operation
is required to exceed the 200

- foot limitation imposed by the po licy, a separate COA specific to the
airspace required for that operation will be obtained prior to operations at an altitude of no more

than 400 feet AGL. All altitudes reported to ATC will be in AGL when required and a ny operations conducted within 5 na utical miles (NM) of the geographic center of a non

- towered
airport will obtain a Letter of Agreement with the appropriate airport management and made

available to FAA upon request. In addition, a ccess to any property will be limited to persons

associated with and necessary to flight operations.

3. Visual Line

- of

- Sight
The minimum crew for each operation will consist of a PIC and VO . The VO will be
used as an additional mitigation to satisfy the VLOS requirement, but the PIC will always

maintain VLOS with the s UAS

. T he S1000 will at all times be flown by Petitioner only in the
daytime (not at night) under VMC

, within VLOS of the PIC

, with the further assistance of the

VO with whom the PIC will have the ability for direct and continuous two

- way verbal

communication s 6 so as to ensure that the flight operations remain w i t h i n the PIC’s VLOS and
prescribed flight boundaries and de

- conflict with objects in the air and on the ground. Thus

, pursuant to the FAA Order 8900.1 Volume 16, Chapter 1, Section 3, the proposed operations

will provide an approved method of control and collision avoidance to satisfy the “ see and

avoid ” requirement of 14 C

. F

. R

. § 91.113 : Only qualified and current PIC’s and VOs , as provided in the SOP will be used

.

4

. Other Factors

6 [ PIC and VO are within speaking distance and all communications between PIC and VO will be without communications equipment ]8 a. S1000 S afety Systems

Petitioner proposes that requirements should take into account the characteristics of th is
particular s UAS

. The S1000 is characterized by a high degree of pre

- programmed control,

various built

- in technical capabilities that limit the potential for operation outside of the
operating conditions as set forth below, and many built

- in functional, safety and redundancy

features to ensure a safe and reliable operation. At a minimum: geo

- fencing at a maximum
ceiling of 200’or 400' AGL, flight programming capabilities, a flight termination link available to
the operator to prevent a "fly away," and safe abort procedures. If the S1000 loses
communications or its GPS signal, it will return to a pre

- determined location and land or be

recovered in accordance with the SOP

. The S1000 will have markings identifying the serial
number and identification (N

- number) markings as large as practic able. Further, Elevated

Horizons operation s will comply with all manufacturer Safety Bulletins. As previously stated,

Elevated Horizons will incorporate the associated DJI A2 F light C ontrol S ystem into the S1000

. The A2 is capable of controlling various multi

- rotor platforms and offers high accuracy
performance through a unique damping design and calibration algorithm. The high performance
of the A2 guarantees stable flight in the presence of high vibration and win ds. The A2 F light

C ontrol S ystem includes the controller unit with a built

- in receiver, a power management unit, an
inertial measurement unit, a Bluetooth unit, and a GPS & Compass. Detailed descriptions of each
subsystem can be seen below.

Controller Unit :

• Output signals for up to eight electronic speed controllers (ESCs)

• Built

- in receiver based on DJI DESST technology, which is compatible

with Futaba FASST and DJI DESST transmitters

o Two available ports for connecting Spektrum or JR DSM2 satell ite

receivers.

• Two CAN

- Bus ports

o Sensors

o Power Management

• Four independent and configurable output channels

Power Management Unit:

• Provides dual Battery Eliminator Circuits (BECs)9 o PW port provides power to the whole flight control sys tem with

current no more than 2A

o PX port provides 3A at 5V and V

- SEV signal

• Two CAN

- Bus ports for connecting peripheral devices

Inertial Measurement Unit:

• High quality components, with build in damper, precisely calibrated
with temperature com pensation in all gyros and sensors

• Built

- in pressure sensor for altitude determination

Blue Tooth Unit :

• Connects to ground station for real

- time parameter configuration, flight
monitoring, and waypoint navigation

GPS & Compass

• Dete rm ines aircraft in ertial position

• Measures geomagnetic field for correcting heading estimations

b

. Safety Management System
A Safety Management System (SMS) approach will regulate Petitioner ’s operation of

the S1000 and will significantly contribute to maintaining the level of safety contemplated by

the airworthiness certificate requirements from which Petitioner now seeks relief.

Pursuant to the S MS and 14 C.F.R. § 43.13, entitled Performance Rules (general)

, each

person performing maintenance, alteration, or preventive maintenance on the S1000 , motor, propeller, or appliance shall use the methods, techniques, and practices prescribed in the

current manufacturer's User’s Manual or Instructions for Continued Airworthiness prepared by

its manufacturer, or other methods, techniques, and practices acceptable to the Administrator.

Each person shall use the tools and e quipment necessary to assure completion of the work in

accordance with accepted industry practices.

c. Flight Operation L imitations and Safety
To ensure consistent safety operations, Petitioner has developed a SOP Manual based

upon procedures , notices and guidance the FAA has provided to obtain exemption under

Section 333

, ( submitted on a proprietary and confidential basis to the FAA ).
In seeking this exemption, Petitioner proposes to operate the S1000 pursuant to the
following specific operating limitations :10

1. The S1000 shall only be operated at or below 2 00 ft AGL , unless a separate COA
specific to the airspace required for that operation is obtained prior to operations at

an altitude of no more than 400 feet AGL.

2. The S1000 shall be operated within VLOS of the PIC and safety VO.

3. The S1000 shall be operated pursuant to Day Visual Flight Rules (VFR) in visual
meteorological conditions (VMC). The S1000 shall be operated only during
daylight hours ( i.e. between the end of morning civil twilight and the beginning of
evening civil twilight, as published in the American Air Almanac, converted to

local time).

4. The radio frequencies used for operations and control of the UAS (2.4GHz) will
comply with the Federal Communications Commission ("FCC") or other
appropriate government oversight agency requirements.

5. The S1000 shall operate from on

- site takeoff/landing locations directly next to the

PIC and co

- located VO. The PIC and the VO shall be able to verbally
communicate during all operations.

6. Operations shall be conducted by certificated airmen who possess either a
commercial, private, recreational, or sport pilot certificate.

7. The PIC will be a FAA licensed airman and will hold a current airman medical certificate or valid U.S. driver’s license issued by a state, the District of Colombia,
Puerto Rico, a territory, a possession, or the Federal government. The PIC will also
meet the flight revie

w requirements specified in 14 CFR § 61.56 in an aircraft in which
the PIC is rated on his or her pilot certificate.

8. The PIC shall have successfully completed the training and qualification process as
specified in the Phantom Pilot Training Guide. PIC qu alification flight hours and currency

will be logged in a manner consistent with 14 CFR § 61.51(b). Training operations will
only be conducted during dedicated training sessions.

9. A minimum of three take

- offs and three landings in the preceding 90 days will
be required by the PIC to maintain currency, such log of which shall be made
available to the Administrator upon request.

10. The PIC and VO will have been trained in the operation of s UAS generally a nd
received up

- to

- date information on S1000 operations.11

11. All op era tions will util i z e a VO. The UA will be op e ra t e d within the V L O S o f the

P I C a nd VO a t a ll tim e s. The VO m a y be u s e d to s a tis f y the V L OS re q u i re m e nt a s
lo n g a s the P I C a lw a y s m a int a ins V L O S ca p a bili t y . T h e VO a nd P I C will be a ble

to c ommuni ca te v er

b a l l y a t a ll tim e s; e l ec t r onic m e s s a g ing o r t e x ting is not

p er mitt e d du r ing f

l i g ht op e r a tions. The P I

C will be d e si g n a t e d b e f

o r e t h e f li g ht a nd

c a nnot t ra ns f

e r his or h e r d e s i g n a tion f o r the du ra tion of the f

l i g ht. T h e P I C will

e nsu r e th a t the VO c a n p e r f o r m the d u ti e s re qui re d of t h e VO.

12. The UA will be operated within visual line of sight (VLOS) of the PIC at all
times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman

medical certificate or U.S. driver’s license.

13. If a pilot certificate holder other than the PIC, who possesses the necessary PI C
qualifications, is also present during flight operations, that person can also be
designated as PIC and will foll ow the procedures as defined within the SOP to

assume control.

14. A briefing will be conducted in regard to the planned o perations prior to each
flight as detailed within the SOP

. It will be mandatory that all personnel who are
performing duties within the boundaries of the flight operations safety perimeter
be present for the briefing.

15. Petitioner will obtain an Air Traffic Organization (ATO) issued COA prior to
conducting any actual flight operations. GPI will only operate within the
guidelines of the blan ket 200

- foot COA under the FAA’s interim policy. For
flights above 200 feet AGL, GPI will operate in a confined geographic area as

defined by a separate ATO issued COA.

16. At least three (3) days before scheduled operations, operator shall submit a written

P lan of Activities to the local Flight Standards District Office (FSDO) with
jurisdiction over the area of proposed operations, such submission of which may
be waived with the concurrence of the FSDO. If required by the FSDO to be
submitted, the Plan of Ac tivities shall include: dates and times for all flights; operator’s and on

- scene flight operator’s name and phone number; s UAS make,

model and serial or N

- number; PIC’s name and certificate number; statement that
the operator has obtained permission from p roperty owners and/or local officials to12 conduct the operations (such list of those who gave permission to be made
available upon request); description of the planned flight activity, including, as
applicable, maps or diagrams of the area, city, town, coun ty and/or state over
which the operation will be conducted, and the altitudes essential to accomplish
the operation; signature of the exemption holder or representative.

17. Petitioner will file a NOTAM for each flight no more than 72 hours but no less
than 48 hours prior to each flight with the appropriate FSDO.

18. Any operations that will be conducted within 5 nautical miles (NM) of the
geographic center of a non

- towered airport will obt ain a Letter of Agreement
with the appropriate airport management and made available to FAA upon

request.

19. Prior to flight operations, Petitioner shall coordinate 1 hour ahead of the proposed
flight a communication with the nearest local Air Traffic Control facility
indicating location, altitude and duration of the proposed flight.

20. All required permissions and permits will be obtained from territorial, state,
county or city jurisdictions, including local law enforcement, fire, or other
appropriate government al agencies at least 12 hours in advance of any flight
operation

. 21. The S1000 shall be marked with an identification (N

- Number) in accordance with
14 C.F.R. § 45.23, such markings to be as large as practicable pursuant to 14
C.F.R. § 45.29(f), and identified by a serial number registered in accordance with

14 C.F.R. Part 47.

22. All flights will remain clear and yield the right of way to all other manned
operations and activities at all times, including, but not limited to: ultralight
vehicles, parachute activiti es, parasailing activities, hang gliders, etc.

23. Flights will not be operated less than 500 feet below or less than 2,000 feet
horizontally from a cloud or when visibility is less than 3 statute miles from the

PIC.

24. For the proposed flight operation, only one S1000 shall be airborne at any given

time.

25. The S1000 shall only be operated at or below an airspeed of 1 6 Meters Per

Second ( 31 kts).13

26. Prior to performing any flight operations, the PIC and VO shall have
successfully completed a qualifying process, as provided in the SOP

. 27. Any time the S1000 is operating, all documents required under 14 C.F.R. § 91.9
and § 91.203 shall be available to the PIC at the GCS. Such documents shall be
made available to the Administrator or any law enforcement official upon

request.

28. The S1000 shall not be operated directly over any person, except authorized and
consenting personnel required for f light/ imaging ope rations

. 29. The S1000 s hall at all times be operated to ensure a safe distance away from all
participating and non

- participating personnel, at least 500 feet away from persons
not involved in the flight operations (non

- participating persons) unless:

 Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The operator

must ensure that nonparticipating persons remain under such protection. If a

situation arises where no nparticipating persons leave such protection and are
within 500 feet of the UA, flight operations must cease immediately in a
manner ensuring the safety of nonparticipating persons

.

 The owner/controller of any vessels, vehicles or structures has granted

pe rmission for operating closer to those objects and the PIC has made a
safety assessment of the risk of operating closer to those objects and
determined that it does not present an undue hazard.

30. Prior to performing any flight operations, a pre

- flight check list will be used by a
qualified PIC a s provided in the SOP

. Documentation of such pre

- flight check

shall be made in the aircraft records and such records shall be made available to
the Administrator upon request.

31. The flight will be terminated at 20% battery power reserve or 3 minutes, whichever

occurs first.

32. Prior to each flight

, the PIC shall inspect the S1000

, including any inoperable
components, items or equipment, to ensure it i s in a n airworthy condition for
safe flight. If the inspection reveals a condition that affects flight readiness or
safe operations, the S1000 shall not be operated until the necessary maintenance
has been performed and it is found to be in a condition for safe flight. A ny14 discrepancies and all maintenance or alterations shall be doc umented in the
aircraft records, such records to be made available to the Administrator upon

request.

33. Except as may be designated otherwise for Fail

- Safe operations, t he S1000 shall

take off and land at a location within the boundaries of the subject property next to

the PIC.

34. Upon loss of communication or GPS signal, the S1000 shall return to a predetermined location within the boundaries of the landowner’s property and

land or be recovered in accordance with the Operator’s Manual

. 35. In the event of an emer gency or unanticipated obstacle to planned operations,
the operation shall be aborted and the S1000

, if airborne, shall return to a
predetermined location.

36. The S1000 shall be maintained in accordance with the manufacturer’s
recommended practices and in accordance with the Elevated Horizons

Maintenance Manual , including any amendments or updates thereto. All

amendments or updates shall be tracked and a record of such amendments or
updates shall be maintained and made available to the Administrator upon

request.

37. Elevated Horizons will follow the manufacturer’s aircraft/component,
maintenance, overhaul, replacement, inspection and life limit requirements

. 38. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controlle r or authorized representative.
Permission from property owner/controller or authorized representative will be
obtained for each flight to be conducted.

39. Any incident, accident or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA shall be reported to the FAA’s UAS Integration Office within 24 hours. Accidents shall
also be reported to the National Transportation Safety Board (NTSB). Further
flight operations shall not be conducted until the incident, accident or
transgression is reviewed by the UAS Integration Office and authorization to
resume operations is provided.15 d

. Privacy

Petitioner will comply with all federal, state, and/or local privacy regulations that may
apply in the areas in which Petitioner will operate the S1000 pursuant to this Petition. Further,

Petitioner ’s policy is to avoid operations that might invade personal privacy in accordance

with Petitioner ’s privacy policy available to the administrator upon request

.

e

. Physical Security

In order to ensure its safe and proper us e , Petitioner will be the only operator of the

S1000 and the S1000 will at all times remain in Petitioner ’s custody

. 5

. . Lack of Threat to the NAS, Public, or National Security
For the reasons previously addressed, in cluding meeting Section 333( b)(1) criteria,

Petitioner ’s record of safety and the small size of the s UAS involved and the controlled sterile
area within which they will operate, Petitioner falls squarely within that zone of safety (an
equivalent level of safety) in which Congress envisioned that the FAA must, by exemption,
allow commercial operations of s UAS s to commence immediately. P etitioner will operate the

S1000 in accordance with the aforementioned flight limitations without creating a hazard to

other aircraft or persons or property on the ground . T he fact that each PIC will be required to be
screened by the Department of Homeland Security, approval of the petition presents no threat to national
security

. Further, given its small size and limit load capacity, the S1000 s UAS is incapable of
carrying any substantial external load, including e x p l os i v e m a t e r i a l s or f l a mm ab l e li q u i ds.
For all of these reasons, Petitioner ’s proposed operations using the S1000 qualify for expedited
approval of the sought exemption pursuant to Section 333 for the specified uses and under the
proposed operating requirements and restrictions.

H

. Public Interest Benefits
Granting Petitioner ’s request for exemption would benefit the public and have no adverse effect
on safety for the following reasons

.

1. Public Interest Generally 

### The grant of the requested exemption is in the public interest based on the clear
direction in Section 333 and 49 U.S.C. § 44701(f), the equivalent and enhanced level of
safety of the proposed operations, the significant pub lic benefit, and cost savings to be

realized as a result of the use of sUAS for precision agricultural aerial imaging and
survey services. Moreover, the FAA has granted similar exemptions for sUAS used to16



### conduct high resolution aerial imaging and precisi on agriculture operations

. 7 The S1000 is

a battery powered s UAS that serves as a safe r , more efficient, and economical alternative to larger

and heavier manned aircraft carrying flammable liquid fuels

, traditionally use for precision
agricultural aerial surveying

. This will provide for a n added superior level of safety to persons and property in the air and on the ground than that provided by manned aircraft performing the
same operations. No p ilot or cre w need be airborne and g ranting the exemption would also

decrease the number of manned aircraft in the NAS and, as a result, reduce congestion as well as
the environmental impact of such operations

. Using the S1000 also provides the benefit of greater operational flexibility and reduced cost when compared to manned aircraft.

a

. Increased Aircrew Safety and Reduced Risk to P ersons/ Property On G round

Because the S1000 is unmanned, the proposed operations eliminate the risk to pilot and crew
associated with flying such aerial

- surveying missions in confined airspace at low altitude

. Further,

g iven its small size and weight and low air speed

, using the S1000 also reduces the risk of damage or
injury to persons or property on the ground , and in the air, were there to be a n unfores een mishap

. b

. Reduced Environmental Impact

U sing the S1000 s UAS instead of manned aircraft also benefit s the public by eliminating or
greatly reducing air and noise pollution associated with traditional aerial imaging operations

. Because it is battery power ed and uses electric motors, the S1000 s UAS consumes no fuel

, generates no air pollution

, and creates very little noise . As a result, the public is benefited as a result

of reduced enviro nmental impact, r educed operator and other human exposure , and greater fuel
conservation, which serves additionally to su pport our G overnment’s specific effort s to reduce the

U.S.’s carbon footprint. 8

c

. Fewer Manned Aircraft i n the NAS and Reduced Need for ATC Handling

The Elevated Horizons S1000 also does not require a runway or helipad to takeoff or land
and will not be operated within the close proximity of any airports without prior FAA approval

. As such , fewer aircraft will need to be handled by a ir t raffic c ontrol during ground, takeoff,
departure, arrival, and landing phases. Operations pursuant to this Peti tion will further reduce the

7 Elevated Horizons r e q u e s ts t h at t h e F AA n ot solicit p u b lic c o mm e n t o n i t s petition b eca us e it

w o u ld n o t s et a ny new pr ece d e n t a n d b eca u s e t h e r elief r e q u e s ted is i d e n tic a l to e x e m p ti o n s g r a n ted pr e v i o us l y

. 1 4 C

. F

. R

. § 11.87.
8 Reducing the U.S.’s carbon footprint is a high priority and consistent with the U.S. Environmental Protection Agency’s regulatory efforts to phase out the use of fossil fuels

.17

number of manned aircraft flying or transiting at or above 500’ AGL to and from the areas of
imaging operations as well as congestion around airports due to aircraft arrival and departure.

d

. Superior Aerial Imagery and Increased Benefit to U.S. E conomy

B etter aerial footage can also be obtained using the small and nimble S1000 than can be

obtained using manned aircraft or other ground

- based methods

. Due to its small size and superior
flight performance characteristics, the S1000 allows for images to be taken from certain locations and
angles and with better precision than using manned aircraft

. As a result, less time is needed in the air

to obtain th e desired footage

, which in addition to providing the benefit of fewer aircraft in the NAS

and associated reduced risk to objects and persons and property in the air and on the ground, reduced
noise, etc., allows for the production of surveys , which benefit s consumers

. This additionally ensures
that companies such as Elevated Horizons and its customers remain competitive and profitable,
thereby providing their employees greater job stability, which ultimately contributes further to the

U.S. econom y through increased consumer spending

.

e

. Increased Operational Flexibility and Reduced Cost
Using the S1000 also provides the benefit of greater operational flexibility and reduced cost

when compared to manned aircraft. Instead of each time having to hire a manned aircraft at
thousands of dollars/hour, subject to the pilot’s schedule and availability, Petitioner can operate

the S1000 , which it has purchased and outfitted at lower combined cost

, innumerable times and at the

convenience of Petitioner ’s and its customer ’ s schedules

. 2. No Adverse Safety Effects
Granting this Petition will also not adversely affect aviation safety or pose any undue

risks to the public. The operations pursuant to this Petition will be in accordance with

Petitioner ’s internal SOP , including approved processes and checkli st s an d in c o m p li ance w i t h
all applicable FAA safety policies and guidance. Accordingly, and as detailed herein,

g ranting the requested exemption would not adversely affect safety. Indeed

, as detailed below

, operations pursuant to the limitations and guidelines addressed herein and the safety
procedures, Petitioner w ill provide a n equivalent level of safety to those regulations from

which Petitioner seeks exemption

. The FAA has also recently set prece dence by granting
exemptions with similar aerial imaging parameters in all material respects, to those presented

herein

. For these reasons Elevated Horizons ’s operations pursuant to this Petition also qualify
for an exemption

. I. Exemption s Sought By Petitioner a nd Reasons f or t he Requested Relief18

Pursuant to Section 333, Petitioner seeks an exemption from the requirements of 14

C.F.R. §§ 45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c), 91.121

, 91.151(b)

, 91.405(a),
91.407(a)(1) and (2)

, 91.409(a) (1) and (2), 91.417(a) and (b)

. 1. Section 45.27(a). Location of marks; non fixed

- wing aircraft

. Section 45.27, entitled Location of marks; nonfixed

- wing aircraft

, subsection (a) states
(emphasis added):
(a) Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft
horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks
required by § 45.23.
To the extent subsection 45.27(a) may be deemed to apply to the S1000 s UAS

, Petitioner

seeks an exemption from the subsection ( i.e., that the marks be displayed on both surfaces of the
cabin, fuselage, boom, or tail) because the S1000 s UA S is of insufficient size to accommodate
any such marking. Thus marking the S1000 s UA S as required by this subsection would not be
possible.

An e q u i v a l ent l e v el of s a f e t y can be provided instead by marking the S1000 s UA S , as may be applicable, with lettering as large as practicable ( 14 C.F.R. § 45.29(f) ) on its largest
available surface so as to permit such marking to be displayed to pilot, crew, and others both

when the S1000 s UA S is on the ground and airborne

. 2. Section 61.113(a) and (b). Private pilot privileges and limitations: Pilot in

command

. Petitioner seeks an exemption from 14 C.F.R. 61.113(a) and (b). Section 61.113, entitled
Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) state
(emphasis added):
(a) Except as provided in paragraphs (b) through (h) of this section, no person who
holds a private pilot certificate may act as pilot in command of an aircraft that is
carrying passengers or property for compensation or hire; nor may that person,
for compens ation or hire, act as pilot in command of an aircraft

.
(b) A private pilot may, for compensation or hire, act as pilot in command of an
aircraft in connection with any business or employment if:
(1) The flight is only incidental to that business or employ ment; and
(2) The aircraft does not carry passengers or property for compensation or

hire.19

In general, subs ec t i ons 61

. 113 ( a ) and ( b ) prohibit a p r i v a t e p il o t from conducting

co m m e r c i al ope r a t i on s . Petitioner seeks exemption from the subsections because t he S1000 w i l l

not ca rr y a p il o t
, passe n g e r s or property (other than a camera). As addressed, the S1000 is a very
light, remotely controlled s UAS with no persons or property on board. The area of operations is
generally remote or sparsely populated. Each f li g h t is p l anned and fully coo r d i na t ed i n a d v ance in accordance with those procedures provided in the SOP

. Thus t he r i s k assoc i a t ed w i t h the
proposed ope r a t i on s is so d i m i n i shed fr om that ass o c i a t ed w i t h co m m e r c i al ope r a t i ons

con t e m p l a t ed by P a r t 61, t hat a ll o w i ng a P IC having a private pilot certificate , rather than a
commercial certificate, met the minimum flight hour and qualification criteria, and operating
according to the limitations and guidelines provided herein

, provides a level of safety that

e x ceeds t hat p r o v i ded by a pilot having a co mm e r c i al ce r t i f i ca t e op e r a t i n g a con v en t i onal a i r c r a f t

as required under the regulations

. T he FAA has already set precedence by previously granted e x e m p t i ons in circumstances
similar, in all material respects, to those presented herein

. 3. Section 91.7(a). Civil Aircraft Airworthiness

. Either finding that Petitioner meets the Section 333 criteria or exemption from the
airworthiness certification requirement under 14 C.F.R. Part 21 renders subsection 91.7(a)
inapplicable.

Section 91.7, entitled Civil aircraft airworthiness

, subsection (a ) states (emphasis added):

“ No person may operate a civil aircraft unless it is in an airworthy condition .” T here is no FAA
standard by which such a determination of airworthiness can be made. Nonetheless, given t he
limitations and procedures , as con t a i ned herein, the S afety Procedures contained within the the

SOP , and the Maintenance Manual

, for maintaining the aircraft and checking it before each
flight to ensure that it is in peak operational condition, an e q u i v a l ent l e v e l o f s a f e t y w il l be

p r o v i ded.

4

. Section 91.105. Flight crewmembers at stations

. Petitioner seeks an exemption from 14 C.F.R. 91.105. Section 91.105, entitled Flight

crewmembers at stations

, states (emphasis added):
(a) During takeoff and landing, and while en route, each required flight

crewmember shall

—20 (1) Be at the crewmember station unless the absence is necessary to
perform duties in connection with the operation of the aircraft or in
connection with physiologic al needs; and
(2) Keep the safety belt fastened while at the crewmember station.

(b) Each required flight crewmember of a U.S.

- registered civil aircraft shall,
during takeoff and landing, keep his or her shoulder harness fastened while at his
or her assig ned duty station . This paragraph does not apply if

— (1) The seat at the crewmember's station is not equipped with a shoulder
harness; or

, (2) The crewmember would be unable to perform required duties with the

shoulder harness fastened.

In general, S ec t i on 91

. 105 requires pilot and crew to be at their duty stations and
harnessed during flight

. Petitioner seeks exemption from the Section 91.105 because the S1000

s UA S is by definition an unmanned aircraft, having neither pilot nor crew so as to be stationed or
harnessed as required by the regulation. An e q u i v a l ent or even higher l e v el of s a f e t y can be
provided instead by using an unmanned aircraft controlled by a PIC who at all times is located at

and controls the S1000 from the GCS.

5

. Section 91.119(c). Minimum safe altitudes

. Petitioner seeks an exemption from 14 C.F.R. 91.119(c). Section 91.119, entitled Minimum
safe altitudes: General

, subsection (d) states (emphasis added):
Except when necessary for takeoff or landing, no person may operate an aircraft
below the following altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface

, except over open water or sparsely populated areas. In those cases, the aircraft
may not be operated closer than 500 feet to any person, vessel, vehicle, or

structure.

S ec t i on 91

. 119(c) e s t ab li shes s a f e a l t i t ud e s f

or ope r a t i on o f c i v i l a i r c r a f t over other than
congested areas

. Petitioner seeks exemption from subsection 91.119(c) because, pursuant to this
Petition, t he S1000 s UA S w il l at times be ope r a t ed at or below 200 or 4 00 feet A G L

. An e q u i v a l ent or even higher l e v el of s a f e t y can be provided instead by, as provided
herein, ope r a t ing so as to de

- conflict with manned vehicles operating above 500 feet AGL , within21

the VLOS of the PIC with the assistance of a VO so as to ensure the safety of and de

- confliction
with any persons or property in the air and on the ground , including participating and non

participating personnel, 100 feet and 500 feet, respectively, away from who the UA would
generally be restricted . Further t he S1000 s UAS flight operations will be m on i t o r ed at all

times by bo t h t he PIC and VO and will be i n c o m p li ance w i t h l ocal pub li c s a f e t y r e q u i r e m en t s ,
so as to prevent access to t he restricted a r eas o f ope r a t i on.
The FAA has set precedence by previously granted e x e m p t i ons in circumstances similar,

in all material respects, to those presented herein

.

6

. Section 91.121. Altimeter settings

. Petitioner seeks an exemption from 14 C.F.R. 91.121

. Section 91.121, entitled Altimeter
settings

, requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” Petitioner seeks exemption from S ection 91.121 because the

S1000 s UAS does not use or have on board a typical barometric altimeter as contemplated by the
regulation.

Note: An equivalent level of safety will be provided instead, by operating the s UAS at

or below 400 feet AGL

, within the VLOS of the PIC (with the assistance of a VO)

, with altitude

information downlinked from the S1000 to the PIC to maintain altitude and ensure safety. Prior
to each flight, a zero altitude/AGL will be established at the launch site, as confirme d for
accuracy by the PIC.

7

. Section 91.151(b). Fuel requirements for flight in VFR conditions.

Petitioner seeks an exemption from 14 C.F.R. 91.151(b). Section 91.151(b), entitled Fuel
requirements for flight in VFR conditions

, states (emphasis added):
(b) No person may begin a flight in a rotorcraft under VFR conditions unless
(considering wind and forecast weather conditions) there is enough fuel to fly to
the first point of intended landing and, assuming normal cruising speed, to fly
after tha t for at least 20 minutes

.

The S1000 is an unmanned aircraft, and thus would not begin a flight with a person in it
as the regulation contemplates . To t he extent the regulation applies to the S1000 , the S1000 has
a maximum flight duration of 15

- 18 minutes

, depending upon atmospheric conditions and type

of camera or sensor.22

A n e q u i v a l ent l e v el of s a f e t y can be ach i e v ed by terminating the flight at 20% battery

power reserve or 3 minutes w h i ch e v er occurs f i r s t, as provided in the SOP . Given that the

S1000 will be operated within the VLOS of the PIC, within the confines of the particular landowner’s property with prior written consent of the landowner and participating and non

participating personnel, this restriction would provide more than enough bat tery reserve to accommodate a safe return to the landing zone from anywhere in the operating area with no
adverse effect on the safety of persons and property in the air or on the ground.

The FAA has set precedence by previously granted e x e m p t i ons in circumstances similar,

in all material respects, to those presented herein

.

8

. Sections 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). Maintenance
inspections and recording

. Section 91.405(a) , entitled Maintenance required

, states:

Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and
shall between required inspections, except as provided in paragraph (c) of this
section, have discrepancies repaired as prescribed in part 43 of this chapter ;

Section 91.407(a)(1) , entitled Operation after maintenance, preventive maintenance, rebuilding,

or alteration

, states:
(a) No person may operate any aircr aft that has undergone maintenance,
preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by a person authorized under
§ 43.7 of this chapter;

Section 91.409 (a)(2) , entitled Inspections

, states:
(a) Except as provided in paragraph (c) of this section, no person may operate an
aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in acco rdance with part 43 of this chapter and
has been approved for return to service by a person authorized by § 43.7
of this chapter; or
(2) An inspection for the issuance of an airworthiness certificate in
accordance with part 21 of this chapter

.23

No inspection performed under paragraph (b) of this section may be substituted
for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection
in the required maintenance records.

Section 91.417(a) and (b) , entitled Maintenance records

, state:
(a) Except for work performed in accordance with §§ 91.411 and 91.413 , each
registered owner or operator shall keep the following records for the periods
specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive mainte nance, and alteration and

records of the 100

- hour, annual, progressive, and other required or approved
inspections, as appropriate, for each aircraft (including the airframe) and each
engine, propeller, rotor, and appliance of an aircraft. The records must include

—
(i) A description (or reference to data acceptable to the Administrator) of
the work performed; and
(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the

aircraft for r eturn to service.

(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller,

and each rotor.
(ii) The current status of life

- limited parts of each airframe, engine,
propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which
are required to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since
the last inspection required by the inspection program under which the
aircraft and its appliances are maintained.
(v) The current status of applicable airworthiness directives (AD) and
safety directives including, for each, the method of compliance, th e AD or
safety directive number and revision date. If the AD or safety directive24 involves recurring action, the time and date when the next action is
required.
(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each
major alteration to the airframe and currently installed engines, rotors,
propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods
prescribed:
( 1) The records specified in paragraph (a)(1) of this section shall be retained until
the work is repeated or superseded by other work or for 1 year after the work is
performed.
(2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.
(3) A list of defects furnished to a registered owner or operator under § 43.11 of
this chapter shall be retained u ntil the defects are repaired and the aircraft is
approved for return to service.

In general, t hese r e g u l a t i ons r e q u i r e t h a t an airworthy certificated a i r c r a f t be i nspec t ed as

p r e s c r i bed i n 14 C.F.R. Part 91, S ubpa r t E (Maintenance, Preventive Maintenance, and
Alterations), any d i sc r epanc i es be r e pa i r ed and the aircraft be approved for return to service a s prescribed in Part 43 (Maintenance, Preventive Maintenance, Rebuilding, and Alterations) and
that any work on the aircraft be recorded and such records maintained.
Petitioner seeks an exemption because, as addressed, the S 1000 sUAS will operate
pursuant to this Petition without airworthiness certification. An equivalent level of safety can be
provided instead by requiring, as provided herein, that inspections and maintenance be
accomplished according to the inspection, mainten ance, and preflight sections of the

Maintenance Manual and SOP, and IAW the manufacturer’s guidance in the S1000 User’s

Manual. Among other things, the S 1000 will be inspected prior to each flight to confirm that it
is in good working order. Any maintena nce or repairs will be perform and logged, and, upon
any work being performed on the S 1000 , it will be checked and approved for flight by personnel
before being returned to service.
The FAA has set precedence by previously granted exemptions in circumsta nces similar,
in all material respects, to those presented herein.25

J. Conclusion
As set forth in the document above, the following summary is provided for publication
in the Federal Register. Petitioner seeks an exemption pursuant to Section 333 of the FAA
Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and 14 C.F.R. Part 11 to permit
safe operation of the S 1000 sUAS commercially, for the purposes of aerial imagery and
surveying relating to precision agriculture. By granting this Petition, t he FAA Administrator
will be fulfilling the Congressional mandate of Section 333 of the FAA Modernization and
Reform Act of 2012 to expedite approval of operations of certain sUAS in the NAS, while also
advancing the interests of the public.

WHEREFORE , in accordance with the Title 49 of the United States Code, the Code of
Federal Regulations, and the FAA Modernization and Reform Act of 2012, Section 333,
Petitioner respectfully requests that the Administrator grant this Petition for an exemption from

the re quirements of 14 C.F.R. §§ 45.27(a), 61.113(a) and (b), 91.7(a), 91.105, 91.119(c),
91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (b), and 91.417(a) and (b).

c c: Ty Rosier, Elevated Horizons, LLC